SPS Corporation Pty Ltd (“SPS”), and its related companies, including Anton’s Mouldings Pty Ltd (“Antons”), Bellini Moulding Pty Ltd (“Bellini”), NCE Pty Ltd (“NCE”), collectively, the “SPS Group”, recognise that your privacy is very important. We understand that providing your personal information to us requires trust and we take that trust very seriously.
The SPS Group complies with the 13 Australian Privacy Principles (APPs) in the Privacy Act 1988 and all relevant privacy laws, including the Health Privacy Principles under state legislation (e.g. those contained in the Health Records Act 2001 (Vic) or the privacy provisions contained in Part 2 of the Health Records (Privacy and Access) Act 1997 (ACT)), the Privacy Regulations 2013 and the Privacy (Credit Reporting) Code.
What is personal information?
Personal information is any information or an opinion about you that is reasonably capable of identifying you. It includes everyday information (e.g. name, address, phone number, credit card details). It also includes the opinions of others about you that could identify you.
What is sensitive information?
Sensitive information is a special category of personal information. It is information or an opinion about your:
• Racial or ethnic origin;
• Political opinion;
• Membership of a political association or religious beliefs, affiliations or philosophical beliefs;
• Membership of a professional or trade association or membership of a trade union;
• Sexual preferences or practices;
• Criminal record;
• Health or disability; and
• Expressed wishes about the future provision of health services.
We do not actively seek to collect sensitive information unless it is necessary for our business purposes. If we do have to collect sensitive information, we will do so in accordance with the Australian Privacy Principles, including by obtaining your consent.
Collection of personal information
We generally collect information from you to make it easier and more rewarding for you to use our products and services. We may collect personal information from you in a variety of scenarios, including (without limitation):
• If you request products or services from us (including via any of the websites of the SPS Group - the “Websites”), we may collect information such as your name and contact details (ie billing and/or postal address, phone/fax number(s) or email address), date of birth and/or credit card details.
• If you make an inquiry, provide feedback or make a complaint to us, we may collect your name and contact details.
• If you are applying for employment with us, we may collect any information that is relevant to such employment including:
o your name and contact details (ie residential address, phone number(s) and/or email address); and
o any other information relevant to the recruitment process (including any information contained in the application form and your resume).
SPS Group may also automatically receive and record information on its server, logs from your browser including your IP address, and the date and time of your access. We use this information for statistical demographic purposes only. We do not access or use personally identifiable information and only treats the data in an anonymous manner.
Where we receive unsolicited information (such as through our Facebook pages or other social media platforms) we will determine, within a reasonable period of time, whether or not we would be permitted to collect the information under the APPs. If it would not be permitted for to collect the information, we will destroy the information or ensure it is de-identified as soon as practicable. Otherwise, we may retain the information in accordance with the terms of this policy.
Use of personal information
SPS Group will use the personal information it collects for the following purposes:
• providing the products and/or services you have requested from SPS Group including for example:
o to process sales transactions;
o to deliver the products or services to you;
o to register you for a service requested by you, such as our newsletter(s) and e-newsletters, mail outs, rewards program(s) or competitions and administering such services;
o to manage warranty claims;
o to respond to any inquiries, feedback or complaints made by you; and
• direct marketing of products and services which we believe may interest you, including product updates and developments, special events or promotions;
• assisting us to improve our products and services and making them more relevant to you;
• assisting us to improve our Websites or Facebook pages;
• processing and assessing employment applications for current and future positions; and
• otherwise managing our internal business operations and processes.
SPS Group will only use your personal information for the purpose of direct marketing activities where we have obtained your consent to do so, or in circumstances where we have collected the information directly from you and you would reasonably expect that your personal information would be used or disclosed for this purpose. We may also share your personal information with our related entities, so that they can provide you directly with marketing material about their products and services.
We will provide you with the opportunity to “opt out” of receiving marketing materials at the time of collection and/or at any time afterwards by either unsubscribing from the email service or contacting our Privacy Officer via the contact details provided below.
Disclosure of personal information
There will be occasions where it will be necessary for the SPS Group to disclose your personal information to third parties. For example, the SPS Group may disclose your personal information to:
• contractors and third party service providers on a confidential basis that we use in the ordinary course of our business to assist with the delivery of the product or service. This includes organisations such as marketing agencies, data processing companies, printing and mailing houses, delivery companies, or finance agencies or debt collection agencies;
• government authorities or other third parties as required by law; or
• any other purpose that you have consented to.
The SPS Group will generally not disclose your personal information to an organisation or individual outside Australia unless, generally, the country to which it is being disclosed has a similar level of privacy protection, or you, or your authorised or legal representative, has consented to the disclosure. If we do disclose your personal information overseas, we will also take adequate measures to ensure that the personal information is handled by the overseas recipient in accordance with the Privacy Act 1988 (Cth) and our instructions for the purposes described above. Personal information you provide to us via the Websites will be securely stored in a combination of electronic and hard copy files. Some electronic information is stored securely Canada and the USA by k-e commerce.
Security of information collected
SPS Group will endeavour to protect the confidentiality of your personal information, account information and personal communications. We use appropriate encryption software to protect your information submitted via the Websites from misuse, loss and unauthorised access or modification.
All personal information (other than credit card information) that is submitted for processing is confined to the offices of SPS Group. Only employees who need to access the information and/or data to perform a specific job (such as invoicing, customer service, order processing) are granted access to personally identifiable information. Unfortunately, no data transmission over the Internet can be guaranteed to be totally secure. While we endeavour to prevent your personal information from misuse or unauthorised access, we cannot guarantee the security of any information you transmit to us or receive from us. As you conduct this activity at your own risk, SPS Group accepts no responsibility for misuse of your personal data which arise from unauthorised access.
The SPS Group may provide ‘commercial credit’ for the purposes of the Privacy Act to businesses who apply for credit in relation to our products and services. "Credit information" relates mainly to your credit-related dealings with us and comprises various types of information collected by credit reporting bodies ("CRBs") that report on consumer credit worthiness. We may collect or generate various categories of credit information about you. We may also collect "credit eligibility information" about you, which is mostly information provided by CRBs relating to your dealings with other credit providers (for example, financial institutions that provide you with loans or other businesses that provide you with credit in connection with their products or services). "Credit information" and "credit eligibility information" may include:
• identification information: such as your name, address, date of birth or employer;
• consumer credit liability information: being information about consumer credit accounts you hold with other credit providers;
• details about information requests made to CRBs: such as the fact that we or another credit provider have requested credit reporting information about you from a CRB to assess a credit application and various details about the credit you have applied for;
• default information: being information about overdue payments owed by you in connection with consumer credit which have been disclosed to a CRB by other credit providers;
• payment information: being information that an overdue payment has been repaid;
• information about consumer credit-related serious credit infringements;
• new arrangement information: being information about certain credit-related arrangements you may have entered with another credit provider in connection with a consumer credit default or serious credit infringement;
• court proceedings information: being information about certain credit-related judgments;
• personal insolvency information: being information recorded in the National Personal Insolvency Index about bankruptcy or various other insolvency-related matters;
• publicly available information about activities relating to credit worthiness.
Credit eligibility information also includes creditworthiness information that we may derive from data we receive from a CRB, such as a credit risk score. We may collect credit information about you in any of the circumstances described above under the heading "How we collect your personal information" above. We collect credit eligibility information from CRBs but may collect it from other third parties where permitted by the Privacy Act (such as from other credit providers with your consent).
External sites that are linked to or from our Websites are not under our control and you are advised to review their Privacy Policies. Users should note there are inherent risks associated with the transmission of information via the Internet and you should therefore make your own assessment of the potential risk to the security of your information.
Are you under 18?
We do not want to collect personal information from anyone under the age of 18. If you are under 18, you should not enter any information on this Website.
Access and correction
You may request access to your personal information held by the SPS Group by writing to our Privacy Officer at email@example.com. We may ask to verify your identity and for more information about your request. Where we are legally permitted to do so, we may refuse your request and give you reasons for doing so. Where you request your personal information to be updated and there is a dispute about the facts, we will make a note on your personal information of such dispute.
We reserve the right to charge a reasonable administrative fee for access and updating requests.
If you have any questions in relation to your privacy or wish to make an access request or a privacy complaint, please email our Privacy Officer at firstname.lastname@example.org.Our Privacy Officer will contact you within a reasonable time after receipt of your request or complaint.